Dentsu, Inc. W3C DRM Working Group Position Paper

Introduction

Dentsu's interest in The World Wide Web Consortium's work in the area of
digital rights management standardization stems from its overall interest in
promoting global, interoperable rights management, without which the proper
development of the world wide web as a suitable medium for communications and
commerce will be inhibited.

Interoperablity and Innovation

As already well noted by other participants in the forum, solutions are
needed that can provide a suitable level of consistency and interoperability
among a great diversity of technologies, policies, media and markets. At the
same time, technological innovation and competition must not be stifled by the
imposition of any standard that could limit differentiation among technology
and content providers on the basis of superior delivery mechanisms and/or more
compelling user propositions.

Technology Is Not the Whole Problem, or the Whole Solution

Equipping content holders to express the conditions by which their
contents/services may be acquired and providing users of those
contents/services to enjoy their full right to such uses without unnecessary
restriction or impediment presents significant obstacles, not all of which are
technical. Differences in intellectual property policy across media and
markets, along with the unprecedented multiplication of intersecting and
competing digital media technologies, business models and standards, together
account for a large part of the difficulty. The web itself, by providing a
different kind of context for contracts of all kinds calls into question the
extent to which existing rights-related structures, conventions and methods
should carry over into what many argue is in some ways a new realm. Without
clarification and unification of the necessary content identification, rights
and usage rules description that must underlie any DRM solutions, any lasting
form of interoperability will prove elusive. Long-term formalization of those
elements will in turn depend on issues of public policy, including
intellectual property, freedom of information and privacy rights, which
transcend the work of individual technical standards groups.

First, Establish A Baseline

Even given these significant obstacles, we hold that a baseline set of
functions that enables as simple, and as technology, media and market-
independent expression and interpretation of rights and permissions
information as possible could provide the necessary starting point from which
the interests of both innovation and interoperability can be served. Such a
baseline should be designed to accommodate ongoing development and
re-evaluation, even re-invention, as it serves to accommodate emergent
requirements. Pursuing such a baseline set of functions, and rigorously
assessing its prospective ability to accommodate the dual ends of
interoperability and innovation in a rapidly evolving global digital
environment is an effort we enthusiastically support.

Memories & Melodies

Memories & Melodies, Dentsu's own approach to embodying the intentions
of content owners in a form that can be acted upon by digital distributors and
in turn conveyed to consumers is in an advanced stage of development, and
provides the informational infrastructure for several existing and emergent
forms of digital content distribution which depend on the uniform expression
of content holders' rights. Through our participation in W3C we hope to extend
Memories & Melodies potential for full interoperability with other
systems, and to assist in the development of a sufficient level of
standardization to fully serve the needs of all stake holders in the future of
digital distribution.

Conclusion

Along with others participating, we recognize the value of other ongoing
standardization work, including but not limited to MPEG-21, and trust that
communication and cooperation with relevant efforts will be diligently
maintained within the scope of this activity. Finally, we much appreciate the
W3C's willingness to permit Dentsu to attend this event despite our late
registration, and look forward to a productive and fascinating session.